NC0020559_Pretreatment Compliance Inspection_20240628

DocuSign Envelope ID: 6E45A538-766A-4EE3-8D3C-llD27D07A10B
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Christy Lipscomb
WRF Director
City of Henderson
P.O. Box 1434
Henderson, NC 27536
NORTH CAROLINA
Environmental Quality
June 28, 2024
Subject: Pretreatment Compliance Inspection
City of Henderson Water Reclamation Facility
NPDES Permit No. NCO020559
Vance County
Dear Ms. Lipscomb:
On June 20, 2024, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of City of Henderson's pretreatment program. The
assistance given by Mr. Brandon Elliott, Pretreatment Coordinator of the facility, was greatly
appreciated. The inspection report is attached. Findings during the inspection were as follows:
1. There is only one Significant Industrial User (SIU) discharging to the POTW, which is
not a Categorical Industrial User (CIU). It was noted that the SIU (Mars Petcare) was not
in Significant Non -Compliance (SNC) for the two most recent semi-annual periods.
2. The review of Long Term Monitoring Plan (LTMP) data indicated that all locations were
sampled with required frequencies and all samples analyzed with correct detection limits
since last inspection. LTMP data were well maintained in spreadsheets.
3. A review of the files containing the pretreatment program elements was conducted. All
elements were up to date. Files were available and well organized. Update of Long Term
Monitoring Plan (LTMP) and Headworks Analysis were received by the Division on
March 27, 2024 and September 11, 2023, and in review.
4. Mars Petcare's pretreatment file (Permit No. 0011) was reviewed during the inspection.
During the second semi-annual period of 2023, the SIU was compliant.
The City of Henderson's pretreatment program is very well managed. Thank you for your
continued support of the Pretreatment Program. If you have questions regarding to the attached
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
n�,Mo E,Amnm W1 Q. 1K,

DocuSign Envelope ID: 6E45A538-766A-4EE3-8D3C-11D27D07A10B
report or any of the findings, please contact Cheng Zhang at 919-791-4200 (or email:
[e-mail]).
Sincerely,
DocuSigned by:
Vaun t,ssa f. Ili aun ut,l,
B2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Enclosure: City of Henderson PCI Form
Cc: Central Files (Laserfiche)
Brandon Elliott - City of Henderson (electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000
nnpn .mo EnWromm�nfal n..

DocuSign Envelope ID: 6E45A538-766A-4EE3-8D3C-llD27D07A10B
r C'. NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
Water Resources
ENVIRONMENTAL QUALITY
BACKGROUND INFORMATION [Complete Prior To PCI; Review Prollram Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Henderson
2. Control Authority Representative(s): Brandon Elliott
3. Title(s): Pretreatment Coordinator
4. Last Inspection Date: 09/19/2023 Inspection Type (Check One): ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number MM/DD/YY
I N I C 1 0 10 12101515191 1061201241
7. Current Number Of Significant Industrial Users (SIUs)?
1
8. Number of SIUs With No IUP, or With an Expired IUP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule?
0
14. Number of SIUs on Schedules?
0
15. Current Number Of Categorical Industrial Users CIUs ?
0
16. Number of CIUs in SNC?
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pul
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
[—]YES ® NO
❑ YES ® NO
Limits: None
Reporting: None
dished: None
None
[—]YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 1

DocuSign Envelope ID: 6E45A538-766A-4EE3-8D3C-llD27D07A10B
28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
9/11/2023
® Yes ❑ No
11/4/2019
® Yes ❑ No
4/1/2022
Industrial Waste Survey IWS
4/14/2022
® Yes ❑ No
3/2/2023
® Yes ❑ No
4/30/2027
Sewer Use Ordinance SUO
11/9/2012
® Yes ❑ No
11/19/2012
® Yes ❑ No
Enforcement Response Plan (ERP)
1/24/2020
® Yes ❑ No
2/12/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
1 3/27/2024
® Yes ❑ No
2/14/2020
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29.
User Name
1. Mars Petcare
2.
3.
30.
IUP Number
0011
31.
Does File Contain Current Permit`?
® Yes ❑ No
32.
Permit Expiration Date
4/3/2027
33.
Categorical Standard Applied I.E. 40 CFR, Etc.) Or N/A
N/A
34.
Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
to Permit Issue Date?
35.
Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
36.
a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. []Yes []No
37.
For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑No[g
Organic Management Plan TOMP ?
38.
a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
39.
During the Most Recent Semi -Annual Period, Did the POTW Complete
®Yes ❑ No
its Sampling as Required by IUP, including flow?
40.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes
❑
No
41.
During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
I
F
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
0Yes0No[9
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
production rates and/or flows as Required b IUP?
43a.
During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b.
During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®N/A
All Reporting_Non-Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑No®N/A
c. If applicable, Did POTW resample within 30 days of becoming aware
c.❑Yes❑No®N/A
of SIU limit violations in the POTW's sampling of the SIU?
46.
During the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑ Yes ® No
47.
During the Most Recent Semi -Annual Period, Was Enforcement Taken
❑Yes❑NoON/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
48.
Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N/A
49.
Does The File Contain Proof Of Penalty Collection?
❑Yes❑No®N/A
50.
a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
51.
Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ®No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 2

DocuSign Envelope ID: 6E45A538-766A-4EE3-8D3C-llD27D07A10B
FILE REVIEW COMMENTS:
Mars Petcare was compliant during the most recent semi-annual period.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
1. Industry Inspected:
2. Industry Address:
3. Type of Industry/Product:
4. Industry Contact: Title:
Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ❑ YES ❑ NO
6. Did the POTW Contact Conduct
the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
❑ YES ❑ NO
B. Plant Tour
❑ YES ❑ NO
C. Pretreatment Tour
❑ YES ❑ NO
D. Sampling Review
❑ YES ❑ NO
E. Exit Interview
❑ YES ❑ NO
Industrial Inspection Comments:
OVERALL SUMMARY AND COMMENTS:
Comments: The program is well managed; files are well organized.
Requirements: None
Recommendations: None
NOD: [—]YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ® NO
POTW Rating:
® Satisfactory ❑ Marginal ❑ UnSatisfactory
PCI COMPLETED BY: Chen Zhan2, Raleigh Regional Office DATE: June 20, 2024
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated December 2016 Page 3